Juan Carlos Martinez is a Director at Environmental Incentives and Program Director of the USAID-funded Latin America and the Caribbean Environment Support Services Contract (LAC ESSC). Katherine Connolly is Senior Associate for Business Development and Marketing at Environmental Incentives. Rob Clausen is an independent consultant who contributed to this blog.
Disclaimer: This article was submitted to WorkwithUSAID.org as a guest blog post. The views expressed by WorkwithUSAID.org guest blog contributors do not necessarily reflect the views of the United States Agency for International Development or the United States Government.
Environmental compliance is not just about checking regulatory boxes. As USAID partner countries confront complex challenges, including the impacts of climate change, USAID’s commitment to including environmental considerations in project planning, design, and implementation is essential to achieve sustainability goals, including as articulated in the Agency’s 2022-2030 Climate Strategy. The Strategy lays out how the Agency will “work on the ground with partner governments and local actors to set the global trajectory toward our vision of a resilient, prosperous, and equitable world with net-zero greenhouse gas emissions.”
In our experience, making the most of environmental compliance is all about perspective:
Consider the management of a healthy forest ecosystem—each component part, from the soil microbes to the vegetation and wildlife—to the communities that steward and depend on the goods and services the forest produces—is part of an integrated system that can’t be fully understood or effectively managed in isolation.
In a similar vein, project design and implementation involve a group of activities that must be managed in a coordinated way. Regulations like 22 CFR 216 (“Reg. 216”) provide an environmental lens through which project designers and implementers can better prepare for and manage, the systemic impacts of implementation.
As you prepare your program, consider our three tips to demystify environmental compliance and Reg. 216 based on our recent experience supporting local grantees to prepare for the process through USAID’s Pacific American Fund.
Tip 1: Become familiar with the environmental risk levels associated with the more common project categories.
All projects impact the environment to some extent, but certain types of projects pose higher risks. Again, think of compliance as a planning tool—higher risks do not mean a project shouldn’t be undertaken, but they do mean more detailed planning is required. Accounting for a potential risk will strengthen overall sustainability and can increase the likelihood of achieving a positive project impact. General environmental, climate, and social impacts and mitigation measures for a variety of sectors can be found on the environmental procedures webpage under “sector environmental guidelines. At the same time, the context (location, nearby environment, and current uses) also matters.
Some of the more sensitive project categories include the following:
- Small- and large-scale agriculture (including irrigation)
- Agricultural projects are a core part of USAID’s investment in sustainable development. However, pesticides are common in most agricultural projects and are often overused. Reg. 216 mandates that projects apply integrated pest management and only include pesticides as a measure of last resort. If pesticides are necessary, then a pesticide evaluation report with a safe use action plan (PERSUAP) will be required. If not properly designed, agriculture may also impact soil fertility and water quality, accelerate erosion, and generate waste that must be managed.
- Projects that involve construction will directly impact the environment. If your activity includes new construction, make sure you carefully consider the site characteristics to minimize impacts on natural systems as well as to avoid possible damage from natural events (e.g., hurricanes/typhoons, riparian and coastal flooding, landslides, liquefaction, sinkholes, etc.). Construction site selection must also consider impacts on land ownership, existing human settlements, and associated livelihoods; USAID’s guidelines on Compulsory Displacement and Resettlement (CDR) may come into play. If your project involves construction, review USAID’s construction sector environmental guidance to design an environmental impact assessment and plan for sustainable project management.
- Medical and biohazardous waste present significant environmental risks. Project designers and implementers should clearly outline how they will mitigate medical waste risks to the local population as well as the environment. Such measures could include identifying an appropriate incinerator for waste disposal, an inventory control system to ensure unnecessary waste is not generated, and waste management training. USAID’s Healthcare Waste Environment Sector Guidance provides program designers with clear tools to assess and mitigate environmental impact.
- Protected area management
- As pressure mounts on our remaining natural areas, it is widely recognized in the international development community that efforts to conserve protected areas (terrestrial, marine, and wetlands) and their biodiversity, as well as the ecological services they provide, are critical to sustaining benefits for current and future generations. In many respects, protected areas safeguard some of the resources that enable communities and livelihoods to prosper. Protected areas also are frequently the focus of ecotourism activities, which normally provide employment and other commercial opportunities for local communities. Ecotourism is not without environmental risks, however, and poorly regulated ecotourism programs can have negative impacts. Some protected areas allow for nearby communities to continue with select extractive practices (e.g., collection of dead fuelwood from the forest floor; honey, mushroom, and medicinal plant collection in specified buffer-zone areas; tapping into natural springs for gravity-fed water supply systems; etc.). Unless carefully monitored, all of these actions can produce negative environmental impacts.
- Assessing, mitigating, and planning for risk is central to achieving program impact. It is the responsibility of the implementing partner to design, implement, and report on the effectiveness of mitigation measures.
Tip 2: Seek out synergies with host-country policies.
When planning a new project, keep the local context in mind and engage host-country environmental officials when appropriate. Projects must follow host-country national environmental regulations in addition to Reg. 216. The good news is that many host-country environmental regulations and procedures are largely in alignment with Reg. 216. Seek out synergies where you can and consider including civil servants from the host-country environmental department or agency to review your project proposals. Sometimes, required host-country documents and USAID documents can be combined.
Tip 3: Design for the end user.
Remember, environmental impact assessment is an ongoing process to ensure project safety and success. Too often, implementers develop a practice to be compliant but fail to design that practice with the end user in mind. Consider how planning for compliance can also be a tool to advance local ownership in sustaining development results. Co-creating mitigation and monitoring plans with the project partners—and when conditions allow, the beneficiaries—provides end users the opportunity to adapt best practices to achieve sustainable development.
Given the vast array of project requirements, it’s easy to see how environmental compliance can be overshadowed. Thankfully, USAID designs its projects with its commitment to environmental sustainability in mind, with helpful guidance such as Reg. 216. By demystifying the process, we hope to inspire more compliance champions—project planners, implementers, and partners—that see environmental compliance as a powerful planning tool that is essential to achieve overall goals.
And if you’re looking to dig deeper—USAID offers guidance and tools, including environmental training for Mission staff, implementing partners, and partner government officials via the Environmental Procedures Hub. For any questions or additional information, please feel free to reach out to your Bureau Environmental Officer, Mission Environmental Officer, or Regional Environmental Advisor.